Supreme Court overturns conviction in murder case: Raju @ Rajendra Prasad vs. State of Rajasthan (2022)

Date of the Judgment: 19 September 2022

Citation: [Not Available in Source]

Judges: M.R. Shah, J., Krishna Murari, J.

Can a conviction for murder stand solely on circumstantial evidence if the chain of events is incomplete? The Supreme Court of India recently addressed this crucial question in a case where the accused were convicted based on circumstantial evidence. The court ultimately overturned the conviction, emphasizing the need for a complete and unbroken chain of events to prove guilt beyond a reasonable doubt. This judgment highlights the importance of rigorous standards of proof in criminal cases. The judgment was delivered by a bench comprising Justices M.R. Shah and Krishna Murari, with Justice M.R. Shah authoring the opinion.

Case Background

The case revolves around the death of Narendra @ Goliya, who was found hanging from a tree. The complainant, Prakash, the deceased’s brother, alleged that Narendra’s wife, Suman Devi, was having an affair with Raju @ Rajendra Prasad. This alleged affair and marital discord led to Suman Devi residing at her paternal home. On 26th September 2016, Narendra went to his in-laws’ house to bring back his wife and children. The following morning, he was found dead, with his body hanging from a tree. Prakash accused Suman Devi, her parents, her brother, and Raju @ Rajendra Prasad of conspiring to murder Narendra.

Timeline:

Course of Proceedings

The Trial Court convicted Raju @ Rajendra Prasad and Smt. Suman Devi under Section 302 read with Section 34 of the Indian Penal Code (IPC), sentencing them to life imprisonment and a fine of Rs. 20,000. The conviction was based on the testimonies of the deceased’s daughter (PW-6) and Suman Devi’s sister (PW-7). The accused then appealed to the High Court of Judicature at Rajasthan at Jaipur, which dismissed their appeals, upholding the Trial Court’s decision. Subsequently, the accused appealed to the Supreme Court.

Legal Framework

The case primarily involves the application of Section 302 of the Indian Penal Code (IPC), which deals with the punishment for murder. It states that “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.” Additionally, Section 34 of the IPC, which pertains to acts done by several persons in furtherance of common intention, was also invoked. Section 34 of the IPC states that “When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.”

Arguments

Arguments by the Appellants (Accused):

• The case rests entirely on circumstantial evidence, with no direct evidence linking the appellants to the murder.
• PW-6, the daughter of the deceased and Suman Devi, stated she did not see the appellants kill her father.
• The prosecution failed to establish that the appellants were last seen with the deceased.
• The prosecution did not prove a complete chain of events to conclude that the appellants committed the murder.
• The circumstances relied upon by the prosecution do not definitively point to the guilt of the accused.
• The appellants relied on the judgments in Mohd. Younus Ali Tarafdar Vs. State of West Bengal, (2020) 3 SCC 747 and Anwar Ali and Anr. Vs. State of Himachal Pradesh, (2020) 10 SCC 166, arguing that the circumstantial evidence was insufficient to prove their guilt.

Arguments by the Respondent (State of Rajasthan):

• There were disputes between Suman Devi and the deceased, establishing a motive for the crime.
• Evidence, including the testimony of the deceased’s daughter and Suman Devi’s sister, showed that there were quarrels and threats to the deceased on the night before his death.
• The prosecution established the motive and circumstances leading to the murder.
• The postmortem report confirmed that the deceased was murdered.

Innovativeness of the Argument: The appellants effectively highlighted the lack of direct evidence and the incomplete chain of circumstances, relying on established legal precedents to argue that the prosecution’s case was insufficient for conviction.

Issues Framed by the Supreme Court

The Supreme Court considered the following issue:

1. Whether, in the facts and circumstances of the case, the High Court and the Trial Court were justified in convicting the accused for the offence punishable under Section 302/34 of the IPC based on circumstantial evidence?

Treatment of the Issue by the Court

Authorities

Cases Relied Upon by the Court:

• Babu v. State of Kerala, (2010) 9 SCC 189 – Supreme Court of India: This case was cited to emphasize the principles governing convictions based on circumstantial evidence. It highlighted that the circumstances must be fully established, consistent only with the hypothesis of guilt, and exclude any other reasonable hypothesis.
• Krishnan v. State, (2008) 15 SCC 430 – Supreme Court of India: This case was referred to within the judgment of Babu v. State of Kerala, outlining the tests that circumstantial evidence must satisfy for a conviction. These include the circumstances being cogently established, pointing unerringly towards guilt, and forming a complete chain.
• Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116 – Supreme Court of India: This case was cited to reiterate that the onus is on the prosecution to prove a complete chain of circumstances, and any lacuna in the prosecution’s case cannot be cured by a false defense.
• State of U.P. v. Satish, (2005) 3 SCC 114 – Supreme Court of India: This case was cited to support the view that circumstantial evidence must be complete and exclude other hypotheses.
• Pawan v. State of Uttaranchal, (2009) 15 SCC 259 – Supreme Court of India: This case was cited to reinforce the principles regarding circumstantial evidence.
• Subramaniam v. State of T.N., (2009) 14 SCC 415 – Supreme Court of India: This case was cited to illustrate that living together is not conclusive proof of guilt in the absence of other evidence.
• Ramesh Bhai v. State of Rajasthan, (2009) 12 SCC 603 – Supreme Court of India: This case was cited to highlight that the evidence produced by the prosecution should not make the conviction of the appellant unsustainable.
• G. Parshwanath Vs. State of Karnataka, (2010) 8 SCC 593 – Supreme Court of India: This case was cited to explain the approach to circumstantial evidence, emphasizing that each fact must be proved individually, and the cumulative effect of all proved facts must lead to the conclusion of guilt.
• Mohd. Younus Ali Tarafdar Vs. State of West Bengal, (2020) 3 SCC 747 – Supreme Court of India: This case was cited by the appellants to argue that the circumstantial evidence was insufficient to prove their guilt.
• Anwar Ali and Anr. Vs. State of Himachal Pradesh, (2020) 10 SCC 166 – Supreme Court of India: This case was also cited by the appellants to support their argument that the circumstantial evidence was incomplete.

Legal Provisions Considered by the Court:

• Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder.
• Section 34 of the Indian Penal Code (IPC): This section deals with acts done by several persons in furtherance of a common intention.

Judgment

How each authority was viewed by the Court?

• The Court relied on Babu v. State of Kerala, (2010) 9 SCC 189* and other cases to emphasize that in cases of circumstantial evidence, the circumstances must form a complete chain, excluding any other hypothesis than the guilt of the accused.
• The Court used the principles laid down in Krishnan v. State, (2008) 15 SCC 430*, Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116*, State of U.P. v. Satish, (2005) 3 SCC 114*, Pawan v. State of Uttaranchal, (2009) 15 SCC 259*, Subramaniam v. State of T.N., (2009) 14 SCC 415* and Ramesh Bhai v. State of Rajasthan, (2009) 12 SCC 603* to highlight the requirements for circumstantial evidence to lead to a conviction.
• The Court also referred to G. Parshwanath Vs. State of Karnataka, (2010) 8 SCC 593* to explain that each fact must be proved individually, and the cumulative effect of all facts should lead to the conclusion of guilt.
• The Court considered the arguments made by the appellants based on Mohd. Younus Ali Tarafdar Vs. State of West Bengal, (2020) 3 SCC 747* and Anwar Ali and Anr. Vs. State of Himachal Pradesh, (2020) 10 SCC 166* to accept that the circumstantial evidence was indeed insufficient.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of a complete chain of circumstantial evidence. The Court emphasized that the prosecution failed to prove that the accused were last seen with the deceased, and there was no evidence of what happened after the deceased went to sleep. The Court also highlighted that the testimony of the key witness (PW-6) did not implicate the accused in the murder. The court was concerned that the circumstances relied upon by the prosecution did not conclusively point to the guilt of the accused and that the prosecution failed to prove a complete chain of events.

Fact:Law Ratio Analysis: The court’s decision was influenced more by the factual aspects of the case (60%), specifically the incomplete chain of events and the lack of direct evidence, than by purely legal considerations (40%). This indicates that the court focused more on the factual gaps in the prosecution’s case when arriving at its conclusion.

The Court considered alternative interpretations but rejected them due to the lack of a complete chain of events and the absence of direct evidence. The final decision was based on the principle that in cases of circumstantial evidence, the circumstances must be fully established, consistent only with the hypothesis of guilt, and exclude any other reasonable hypothesis. The Court concluded that the prosecution failed to meet these criteria.

The Supreme Court overturned the conviction of the appellants, stating that the prosecution failed to prove that the appellants alone committed the murder. The court emphasized that the prosecution did not establish a complete chain of events and that there was no evidence that the appellants were last seen with the deceased. The court held that the circumstantial evidence was insufficient to sustain a conviction under Section 302/34 IPC.

“In case of a circumstantial evidence, the circumstances, taken cumulatively, should form a chain so complete that there is no escape from the conclusion that within all human probability the crime was committed by the accused and none else and the circumstantial evidence in order to sustain conviction must be complete and incapable of explanation of any other hypothesis than that of the guilt of the accused and such evidence should not only be consistent with the guilt of the accused but should be inconsistent with his innocence.”

“On considering the deposition of PW-6, who can be said to be the star witness and on whose deposition the appellants – accused are held guilty for the offence punishable under Section 302/34 IPC, even it cannot be said that the prosecution has established and proved that the accused were last seen together with the deceased.”

“Under the circumstances, the prosecution has failed to prove the guilt and complete chain of events, which may lead to the only conclusion that the appellants – accused alone committed murder and/or killed the deceased.”

There were no minority opinions in this case. The judgment was delivered by a bench comprising Justices M.R. Shah and Krishna Murari, with Justice M.R. Shah authoring the opinion.

Key Takeaways

• In cases relying on circumstantial evidence, the prosecution must establish a complete and unbroken chain of events that points unequivocally to the guilt of the accused.
• The prosecution must prove that the accused were last seen with the deceased, especially in cases where there is no direct evidence.
• The testimony of witnesses must be thoroughly examined, and any inconsistencies or lack of direct implication of the accused must be considered.
• The burden of proof lies with the prosecution to prove guilt beyond a reasonable doubt, and any gaps or missing links in the evidence can lead to the acquittal of the accused.
• This judgment reinforces the importance of rigorous standards of proof in criminal cases and highlights the need for a thorough and complete investigation.

Directions

The Supreme Court directed that the judgment and order of conviction passed by the Trial Court and the High Court were quashed and set aside. The accused were acquitted for the offence for which they were convicted and were ordered to be released forthwith, if not required in any other case.

Specific Amendments Analysis

There is no discussion of any specific amendments in the judgment.

Development of Law

The ratio decidendi of this case is that in cases based on circumstantial evidence, the prosecution must establish a complete chain of events, and the circumstances must be consistent only with the guilt of the accused, excluding any other reasonable hypothesis. This case reinforces the established principles regarding circumstantial evidence and highlights that the prosecution must prove the guilt beyond a reasonable doubt. There is no change in the previous position of law, but the judgment emphasizes the strict application of existing principles in cases of circumstantial evidence.

Conclusion

The Supreme Court overturned the conviction of Raju @ Rajendra Prasad and Smt. Suman Devi, emphasizing the need for a complete chain of circumstantial evidence in criminal cases. The court found that the prosecution failed to establish that the accused were last seen with the deceased and did not prove a complete chain of events leading to the conclusion that the accused alone committed the murder. This judgment underscores the importance of rigorous standards of proof in criminal proceedings and reinforces the principle that the prosecution must prove guilt beyond a reasonable doubt.

Category

Parent Category: Criminal Law

Child Categories:
✓ Circumstantial Evidence
✓ Murder
✓ Section 302, Indian Penal Code, 1860
✓ Section 34, Indian Penal Code, 1860
✓ Supreme Court Judgments
✓ Criminal Appeals

FAQ

Q: What does this judgment mean for cases based on circumstantial evidence?
A: This judgment emphasizes that in cases based on circumstantial evidence, the prosecution must establish a complete and unbroken chain of events that points unequivocally to the guilt of the accused. If there are gaps or missing links in the evidence, the accused may be acquitted.

Q: What is the significance of the “last seen” theory in such cases?
A: The “last seen” theory is crucial in cases of circumstantial evidence. The prosecution needs to establish that the accused were last seen with the deceased to strengthen their case. If this is not proven, it weakens the prosecution’s argument.

Q: What should I do if I am accused in a case based on circumstantial evidence?
A: If you are accused in a case based on circumstantial evidence, it is crucial to seek legal counsel immediately. Your lawyer will assess the evidence and advise you on the best course of action. The prosecution must prove your guilt beyond a reasonable doubt.

Q: What is the role of witness testimony in these cases?
A: Witness testimony is vital, but it must be consistent and reliable. If a witness does not directly implicate the accused or if there are inconsistencies in their testimony, it can weaken the prosecution’s case.

Q: How does this judgment impact the common man?
A: This judgment reinforces that the legal system prioritizes the principle of “innocent until proven guilty.” It ensures that individuals are not convicted based on weak or incomplete evidence, safeguarding their rights and liberties.